If you thought Stage 3 of the EHR Incentive Program was being relegated to the regulatory dustbin now that the Centers for Medicare and Medicaid Services has proposed its much-anticipated Medicare Access and CHIP Reauthorization Act (MACRA) rule, think again.

That’s the latest of current thinking from CMS, which late last month published its MACRA proposal, which included the Merit-Based Incentive Payment System (MIPS) for eligible clinicians. Under the proposed rule, Meaningful Use is essentially restructured into a new Advancing Care Information (ACI) performance category as part of MIPS for purposes of calculating payment.

Kate Goodrich, MD
Kate Goodrich, MD

ACI, under MIPS, and Meaningful Use “are the same,” said Kate Goodrich, MD, director of the CMS Center for Clinical Standards and Quality, during a May 17 joint meeting of the Health IT Policy and Standards committees. “Our goal was to not make people have to do something completely different or buy any new technology.”

To earn points toward the base score, a MIPS-eligible clinician must report the numerator and denominator of certain measures specified for the ACI performance category. The measures in that category are based on the measures adopted by the EHR Incentive Programs for Stage 3 in the 2015 EHR Incentive Programs Final Rule, and they’ll account for 50 percent of the ACI performance category score.

“If you just report, you’re going to get half the score. And, then, we on the back end calculate (the other 50 percent) based upon how you do on each measure,” Goodrich told the committees.

While Troy Seagondollar, a member of the HIT Policy Committee, expressed his approval that the proposed MACRA/MIPS rule “truly is incentivizing the continued use of EHRs,” he questioned whether a “carrot and stick” approach of payment adjustments—a legacy of the Meaningful Use program—is the most effective method for driving success.

“The payment adjustments—which is the stick part of Meaningful Use—ends at the end of 2018, because the first payment adjustment, up or down, for MIPS begins Jan. 1, 2019,” responded Goodrich. “That stick goes away and it does get folded into the totality of MIPS. And, by the way, because there isn’t an incentive to get people to adopt EHRs anymore—this is the last year for that anyway—that was the other reason we designed the ACI category the way that we did. It was to try to set a bar we thought people could mostly achieve, but had an opportunity to do really well in to the extent that they could.”

She explained that CMS is proposing a new ACI performance category score under MIPS, in which a meaningful EHR user is defined as a MIPS-eligible clinician who possesses certified EHR technology, uses the functionality of certified EHR technology, and reports on applicable objectives and measures.

Based on MIPS eligible clinicians’ performance on specified measures and activities, CMS would distribute payment adjustments to somewhere between 687,000 and 746,000 eligible clinicians in 2019. The agency projects that MIPS payment adjustments for eligible clinicians—both negative and positive adjustments—will be equally distributed at $833 million, respectively.

“It is based on the clinician’s performance or group practice’s performance on those measures,” Goodrich emphasized. “Just to be clear, the incentives—whether they are up or down—for Medicaid and for hospitals are unchanged. (MIPS) is really about Medicare clinicians.”

As part of the CMS proposal, the first MIPS performance period would start on Jan. 1, 2017, running the full calendar year, with the first MIPS payment year scheduled to begin in 2019. In addition, starting with the performance period in 2018, MIPS-eligible clinicians are required to only use technology certified to the 2015 Edition to meet the ACI objectives and measures.

Goodrich said that the final rule will be published in November. CMS will accept public comments on the proposed rule until June 27.

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